Primary Lead Smelting NESHAP Technical Support Document 

Risk and Technology Review 

National Emission Standards for Hazardous Air Pollutants 

(NESHAP) for the Primary Lead Smelting Source Category 

Technical Support Document 

DRAFT 12/28/10

Docket No. EPA-HQ-OAR-2004-0305 

January 31, 2011 
Primary Lead Smelting NESHAP Technical Support Document 

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Table of Contents 

1.0 Residual Risk Analysis - Development of the Emissions Dataset for the Primary Lead Smelting 

Source Category ............................................................................................................................... 1 

1.1 Emissions Data Sources ...................................................................................................... 2 

1.2 Risk Analysis Emissions Data Set ...................................................................................... 2 

1.2.1 Actual Emissions ................................................................................................... 3 

1.2.2 Allowable Emissions ............................................................................................. 4 

2.0 Calculation of Proposed Emission Limits Based on Modeled Concentrations ................................ 7 

3.0 Estimated Costs of Proposed Revisions to the Primary Lead Smelting NESHAP ........................ 10 

3.1 Emission Control Costs for Acceptability Reductions ..................................................... 10 

3.2 Emission Control Costs for Ample Margin of Safety Reductions .................................... 11 

3.3 Additional Testing and Monitoring Costs ......................................................................... 13

Tables 

Table 2.1 Calculations of Emission Limits Based on Modeled Concentrations 

Table 2.2 Calculation of Proposed Refinery Operation Emission Limit based on Modeled 

Concentrations 

Table 3.1 Cost Effectiveness of Upgrading Baghouses to Membrane Bags for Baghouses 7, 

8 and 9 

Table 3.2 Cost Effectiveness of Adding Additional Baghouses to Control Emissions for 

Baghouses 7, 8 and 9 

Table 3.3 Cost Effectiveness of Upgrading Baghouses to Membrane Bags for Main Stack 

Table 3.4 Cost Effectiveness of Adding Additional Baghouses to Control Emissions for 

Main Stack 

Table 3.5 Additional Testing and Monitoring Costs
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1.0 Residual Risk Analysis ­ Development of the Emissions Dataset for

the Primary Lead Smelting Source Category

This memo describes the development of the dataset used to conduct the residual risk analysis 

under Section 112 (f)(2) of the Clean Air Act (CAA) for the Primary Lead Smelting source 

category. 

Section 112 of the Clean Air Act (CAA) establishes a two-stage regulatory process to address 

emissions of hazardous air pollutants (HAP) from stationary sources. In the first stage, after 

EPA has identified categories of sources emitting one or more of the HAP listed in section 

112(b) of the CAA, section 112(d) of the CAA calls for us to promulgate a National Emission 

Standard for Hazardous Air Pollutants (NESHAP) for those sources. These technology-based 

standards must reflect the maximum degree of emission reductions of HAP achievable (after 

considering cost, energy requirements, and non-air quality health and environmental impacts) 

and are commonly referred to as maximum achievable control technology (MACT) standards. 

The NESHAP for the Primary Lead Smelting source category was promulgated on June 4, 1999. 

The EPA is then required to review these technology-based standards and to revise them “as 

necessary (taking into account developments in practices, processes, and control technologies)” 

no less frequently than every 8 years, under CAA section 112(d)(6). In conducting this review, 

EPA is not obliged to completely recalculate the prior MACT determination. NRDC v. EPA, 

529 F.3d 1077, 1084 (D. C. Cir., 2008). 

The second stage in standard-setting focuses on reducing any remaining “residual” risk 

according to CAA section 112(f)(2) and requires EPA to determine for source categories subject 

to certain MACT standards, whether the emissions standards provide an ample margin of safety 

to protect public health. If the MACT standards apply to a source category emitting a HAP that 

is “classified as a known, probable, or possible human carcinogen do not reduce lifetime excess 

cancer risks to the individual most exposed to emissions from a source in the category or 

subcategory to less than one-in-one million,” EPA must promulgate residual risk standards for 

the source category (or subcategory) as necessary to provide an ample margin of safety to protect 

public health. CAA section 112(f)(2)(A). In doing so, EPA may adopt standards equal to 

existing MACT standards if EPA determines that the existing standards are sufficiently 

protective. 

In order to conduct the risk analysis of sources in the Primary Lead Smelting source category, a 

dataset was developed that included estimates of individual HAP emissions from each HAP 

emitting source as well as source characteristics. The dataset used includes both actual and 

allowable facility emissions and would be used in the emissions modeling exercise to determine 

concentrations of various HAPs at the modeled receptor locations. Those concentrations would 

be compared to the established risk-based threshold for each HAP to determine the potential for 
Primary Lead Smelting NESHAP Technical Support Document 

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residual risk from the emissions. The methods, thresholds, and results of risk analysis and 

modeling are described in the “Residual Risk Assessment for the Primary Lead Smelting Source 

Category” memorandum included in this docket. Below is a discussion of the sources of the 

actual and allowable emissions data and source characteristics used in the risk analysis and 

modeling exercise. 

1.1 Emissions Data Sources

The preliminary sources used to gather emissions and source characteristic data included the 2002 

National Emissions Inventory (NEI) Final Inventory, Version 1 (made publicly available on 

February 26, 2006), and the 2005 National Emissions Inventory (NEI), version 2.0 (made 

publicly available in October 2008). The 2005 NEI was updated to develop the 2005 National 

Air Toxics Assessment (NATA) Inventory. NATA inventory updates for the primary lead 

smelting category included SIP data provided by the state of MO to EPA. These data sets 

include information about sources that emit criteria air pollutants, their precursors, and HAP. 

The NEI database includes estimates of annual air pollutant emissions from point and volume 

sources, emission release characteristic data such as emission release height, temperature, and 

velocity, and location latitude/longitude coordinates. We reviewed the NEI datasets, checked 

geographic coordinates, and made changes based on available information. 

The sole remaining facility in this source category is the Doe Run Company in Herculaneum, 

Missouri. The Doe Run facility has been the subject of many compliance and regulatory actions 

by the State of Missouri and by EPA Region 7 due to efforts to comply with the lead National 

Ambient Air Quality Standard (NAAQS). The controls applicable to the facility in order to meet 

the NAAQS are codified in the Lead State Implementation Plan. In 2007 a SIP demonstration 

was conducted which included modeling of facility emissions to determine compliance with the 

SIP. EPA also reviewed the emissions data used for that demonstration to update the risk 

analysis data set. Since many improvements in emissions controls have been implemented from 

2001 through 2007 due to the 2001 SIP and the 2007 SIP revision, EPA determined that more 

recent data would be necessary to conduct an appropriate risk assessment of the current 

emissions impacts. EPA requested emissions and source control information through a section 

114 information collection request (ICR) in October, 2009. The February, 2010 Doe Run ICR 

response included copies of the emissions inventories that were provided to the Missouri 

Department of Natural Resources (MDNR) for the CY 2000 through 2008. 

1.2 Risk Analysis Emissions Data Set

The analysis performed considers HAPs that are regulated by the existing MACT standard, and 

also considers any other HAPs that have the potential to present risk. The risk analysis considers 

both actual emissions of the facility and the emissions that would be allowable under the MACT 

rule. Once the analysis is complete, EPA determines if any further emission reductions are 
Primary Lead Smelting NESHAP Technical Support Document 

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necessary to assure that an acceptable level of risk is achieved. For the Doe Run facility, we 

determined the actual and allowable emissions as described below. 

1.2.1 Actual Emissions

We reviewed the NEI datasets, checked geographic coordinates, and made changes based on 

available information. We also reviewed the emissions and other data to identify data anomalies 

that could affect risk estimates. Since the 2008 emissions inventory is the most recent emissions 

data source available, and reflects the implementation of the numerous SIP emission reduction 

requirements (as evidenced by the ICR response), EPA determined that the emissions reported 

for the facility in the CY2008 emissions inventory report would be the most representative of 

current facility operations and would also be appropriate for use in the risk analysis. 

The dataset derived from the review of the 2002 and 2005 NEI/NATA data was then updated to 

include the emissions for all sources from the CY2008 emissions inventory report. Any 

differences in the data between the NEI and the CY2008 emission inventory were noted and 

analyzed. If data found in the NEI was not included in the CY2008 emission inventory, but was 

found to be pertinent, then it was included in the data set used for the risk analysis. Any 

discrepancies found between the NEI and the CY2008 emission inventory was discussed with 

the facility. 

One specific change to the dataset derived from the combination of the NEI data and the CY2008 

emission inventory pertained to organic HAP emissions. The 2005 NEI file included several 

sources that emitted trace levels of 25 organic HAP from natural gas and other combustion 

sources primarily through the main stack. The current VOC emission levels as reported in the 

ICR response are well below the level which can be addressed by current controls. In addition, 

the levels are low enough to preclude effectively modeling for risk assessment (i.e. the dispersion 

from the 500 foot stack would effectively put any modeled emissions at zero at receptor sites). 

Therefore, the organic HAP emissions sources were removed from the modeling dataset and not 

considered during the risk analysis. 

The final dataset included emissions of lead compounds and other metal HAP (i.e. antimony, 

arsenic, cadmium, chromium, cobalt, and nickel) which are the HAP currently regulated under 

the MACT standard. 

“Lead compounds” is the primary HAP emitted from the Doe Run facility and accounts for 

approximately 99 percent of the total HAP emitted. Of the lead compound emissions, 

approximately 86 percent is emitted through stacks (point or vertical sources) with the remainder 

being fugitive emissions. The point or vertical sources include stacks that discharge from 

baghouses, heat stacks and roof vents. The MACT emission limit applies to operations that 

discharge through 2 stacks, the main and baghouse #7 stacks which account for 15.1 of the total 

17.9 TPY stack lead compound emissions. Since promulgation of the MACT rule, the facility 
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has captured and controlled all refining operations with two additional baghouses (baghouse #8 

which vents to a stack and baghouse #9 which vents to a common stack with baghouse #7). 

These emissions are included in the table below. Fugitive sources include material handling and 

plant yard and roadway dust. Table 1.1 summarizes the types and volumes of HAP and the types 

of sources included in the dataset for the Doe Run Company facility. Total actual lead emissions 

including fugitive emissions are 20.7 tons per year (TPY). It should be noted that non-volatile 

metal HAP other than lead are reported by Doe Run based on speciation tests conducted for the 

various sources. 

Table 1.1 - Summary of Doe Run Company Risk Dataset Emission Sources 

 Fugitive Stack Total 

HAP 

Number 

 of Sources TPY 

Number 

 of Sources TPY 

Number 

 of Sources TPY 

Lead 115 2.8053 22* 17.9030 137 20.7083 

Antimony 6 0.0028 4 0.0252 10 0.0280 

Arsenic 10 0.0005 6 0.0210 4 0.0215 

Cadmium 12 0.0296 7 0.0823 19 0.1118 

Chromium 0 0.0000 3 0.0056 3 0.0056 

Cobalt 6 0.0005 6 0.0049 12 0.0054 

Nickel 8 0.0019 7 0.0154 15 0.0172 

*Of the 22 stack sources, 2 are included within the MACT emission limit which account for 17.6 of the 17.9 TPY.

The actual emissions dataset for this facility represents the entire source category. Likewise, all 

HAP emission points for this source are included in the risk analysis dataset; therefore, the 

facility-wide emission dataset for this source category is the same as the risk analysis dataset. 

1.2.2 Allowable Emissions

Allowable emissions are emissions that would be allowed under the current NESHAP for 

primary lead smelters. For the Primary Lead Smelting source category and NESHAP, lead is the 

regulated HAP and other non-volatile metal HAP are regulated using lead as a surrogate. 

Therefore, allowable emissions would only apply for the lead compound emissions. For the Doe 

Run facility, allowable lead compound emissions are summarized in Table 1.2. 

Under the NESHAP, an emission limit of 1.0 pound of lead per ton of lead produced (lb/ton) 

applies to the following nine sources: 

1) Sinter machine 

2) Blast furnace 

3) Dross furnace 

4) Dross furnace charging location 

5) Blast furnace and dross furnace tapping location 

6) Sinter machine charging location 
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7) Sinter machine discharge end 

8) Sinter crushing and sizing equipment 

9) Sinter machine area 

Applying the allowable emissions rate of 1.0 lb/ton to the Doe Run’s 2008 lead production of 

149,564 tons, the allowable emissions from the above nine sources would be 74.8 TPY. All 

emissions from the source’s nine emission points listed above are captured and controlled by 

baghouses, which vent to the main stack or the furnace area stack. The total allowable emissions 

were prorated between the two stacks based on the ratio of actual emissions reported for the two 

stacks. 

Note that refining operations are not listed above and are not subject to the 1.0 lb/ton limit in the 

original MACT. At the time the NESHAP was promulgated, refining operations were a fugitive 

emissions source, however, these emissions under the current facility configuration are now 

captured, controlled by a baghouse, and vented through two stacks. As the emissions are no 

longer fugitive, and the MACT emission limit does not apply to the operation, we were unable to 

calculate an allowable emission level for refining operations. 

Under the NESHAP, fugitive emissions are governed by work practices, which under §63.1544 

are defined as the measures that will be “put into place to control fugitive dust emissions.” Thus, 

the actual fugitive emissions, which reflect the measures that have been put in place, would be 

equivalent to the allowable emissions. Fugitive emissions levels were taken from Doe Run’s 

2008 Emissions Inventory that is submitted annually to the MDNR. 

Table 1.2 Summary of Actual and Allowable Lead Emissions for the Doe Run Primary Lead 

Smelter, 20081

Emission Point Processes 

Actual 

Emissions 

(TPY) 

Allowable Lead 

Emissions 

(TPY) 

Main Stack (BH # 3, 5, 6) Sintering, blast furnace, dross 

furnace 

13.31 65.8 

Furnace Area (BH # 7) Smelter building 1.81 8.94 

Refining (BH # 8, 9) Refining kettles and building N/A N/A 

Fugitives Roadways, storage piles, 

materials handling and transport

2.85 2.85 

As shown above, we estimate that MACT-allowable emissions from this source category are 

about four times greater than the actual emissions, based on the MACT limit (1 lb/ton) applied to 

2008 production data and compared to 2008 actual emissions. The modeling file for this risk 

analysis can be reviewed in the EXCEL spreadsheet 

“PrimLead_RTR_ModelingFile_102110_2008_DOE_RUN.xls” available in the docket. 
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References: 

1. Curran, D., Stinson Morrison Hecker, for The Doe Run Company, to Nizich, S., US EPA, 

Response to Section 114 Information Collection Request, February 5, 2010. 
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2.0 Calculation of Proposed Emission Limits Based on Modeled

Concentrations  

The risk analysis process included modeling of actual and allowable emissions to determine the 

anticipated concentration at individual receptor locations. For this source category, the 

emissions for the lead emissions sources were individually modeled for each receptor location 

and the results were compared to the Primary National Ambient Air Standard (NAAQS) for lead 

(0.15 μg/m3

). If the modeled emissions exceeded the lead NAAQS, those locations were 

considered to be exposed to unacceptable risk. The results indicated multiple locations exceeded 

the level of the NAAQS to various degrees. 

Our modeling results indicated that emissions from the main stack did not exceed NAAQS 

within the 50 km radius modeled. The highest concentration location was a point on the property 

boundary. Emissions contributing to this exceedance were found to be cumulative fugitive dust 

emissions from various emission points. Other emission points that resulted in exceedance of the 

lead NAAQS were the furnace area stack and the Baghouse #9 stack for the refinery building, 

both at various census block locations. 

Each emission point (with fugitive dust emissions being treated as one emission point) were 

analyzed to determine what emission levels would be necessary to reduce risk to an acceptable 

level. EPA determined that if the emissions from each emission point were reduced below the 

NAAQS level based on the worst-case or highest location concentration, then all risk for that 

emission point at any location would be reduced to acceptable levels. Therefore, a roll-back 

calculation was conducted to determine what percentage reduction in concentration was required 

for each of the highest concentration locations. Since the relationship between level of emissions 

and modeled concentrations is linear, a percentage reduction could be applied to the actual 

emissions from the CY 2008 emissions inventory for a given emission point that would reflect 

the same reduction in modeled concentration. 

The reduction necessary to address fugitive dust emissions risk was determined to be 98 percent. 

The reduction necessary to address the furnace area stack emissions was determined to be 52 

percent. 

The refinery emissions are vented through Baghouse #8 and Baghouse #9 stacks, and ten heat 

stacks. For the refinery operation, only one stack (Baghouse #9) showed exceedance of the 

NAAQS. The emission reduction found necessary from Baghouse #9 stack is 66 percent, which 

was applied to the total emissions from all of the refinery operation emissions points. 

Table 2.1 summarizes the calculations and recommended limits for the total facility including 

furnace area stack, fugitive dust, and the refinery operations. Table 2.2 summarizes just the 

refining operation calculation, considering all contributing emission points. 
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Table 2.1 - Calculations of Emission Limits Based on Modeled ConcentrationsModeled Source

2008 Emissions 

(tpy)

Highest receptor 

location Concentration Roll back %

Emissions after 

rollback (tpy) No

Stacks  - Main 13.31 0.007 0 13.31 No risk impacts within  - Baghouse #7, furnace area 1.81 0.314 52 0.86 At census block #29099 - Baghouse #8 - refinery kettles 2.03 0.079 0 see below Included in refinery ma - Baghouse #9- refinery buiding 0.45 0.352 57 see below Included in refinery maTotal of BHs 7+8+9 4.29 0.745 80 15.12Refinery stacks 2.74 0.4363 66 0.94 BHs #8, #9 and heat sta

calculation

Smelter Fugitives 2.55 6.94 98 0.06 Fume, sinter and concePlantwide Fugitives 0.39 1.063 86 0.06 Roadays, plant yard, reAll Fugitives 2.94 7.289 98 0.061) Emission Limit Ambient lead concentration at property boundary* 0.15 ug/m32) Emissions Cap  Furance Area stack (BH#7) 0.86 TPY Refinery stacks 0.94 TPY* To address 98% reduction needed from fugitive emissions, with receptor location at property boundary.Calculations Roll back % = (Actual concentration - 0.15)/actual concentration

Emissions after rollback = 2008 emissions * (1-(rollback%/100))

RECOMMENDED ACTIONS

All Modeled Sources
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Table 2.2 - Calculation of Proposed Refinery Operation Emission Limit based on Modeled Concentrations

Modeled Source

Modeled values at the site of max. 

impact for refinery stack sources 

(ug/m3)*

50007 Baghouse #8 Stack 0.070750008 Baghouse #9 Stack 0.315050011 Refinery Kettle Heat Stack 0.001050012 Refinery Kettle Heat Stack 0.001050013 Refinery Kettle Heat Stack 0.001050014 Refinery Kettle Heat Stack 0.001050015 Refinery Kettle Heat Stack 0.001050016 Refinery Kettle Heat Stack 0.001050017 Refinery Kettle Heat Stack 0.001050018 Refinery Kettle Heat Stack 0.0011 Subtotal all refinery stacks 0.4363Ratio of NAAQS to refinery max 0.34 or 0.15/.4364Percent reduction required 0.66 or 1- 0.34TPY emission cap 0.94 or (NAAQS limit * TPY refinery currentlb /ton on rolling avg. 90 days 0.01 or (0.94 *2000 /149,500)

Refinery Maximum Calculation
Primary Lead Smelting NESHAP Technical Support Document 

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3.0 Estimated Costs of Proposed Revisions to the Primary Lead

Smelting NESHAP

    

With regard to lead emissions, we are proposing to require most of the emission sources at the 

facility to implement all technically feasible controls in order to ensure that the ambient air meets 

the level of the lead NAAQS, which is the level we have determined will ensure an acceptable 

level of risk. EPA has determined that lead compound emissions must be reduced to allow for an 

acceptable level of risk for fugitive dust emissions, emissions from the furnace area stack, and 

the refining operation. As a result, the facility will need to implement emission controls or other 

actions that will reduce lead emissions to an acceptable level and to meet the new emission 

limits/caps in this proposed rule. In addition, in order to demonstrate compliance with these 

limits, additional ambient lead continuous monitoring is being required. 

This section summarizes the impacts analysis conducted on all additional emission control 

options that were considered technologically feasible for achieving all necessary reductions as 

well as those monitoring costs necessary to comply with proposed requirements. 

We note that the same controls for the three emission points to reduce lead emissions are the 

same controls that would reduce risks from cadmium and all other metal HAP; therefore we are 

not proposing additional, or other controls for control of other metal HAP. 

For fugitive dust emissions, which are controlled by work practices, no additional controls were 

evaluated because all reasonable practices are currently being implemented. Therefore, there are 

no additional controls and cost impacts considered for fugitive dust emissions however, based on 

our proposed concentration limit, we have evaluated the costs for ambient monitoring to meet the 

requirement. For the four stack emission points, we considered the upgrading of existing 

baghouses from use of cloth bags to membrane bags and addition of an in-series baghouse 

emission as emission reduction options. 

3.1 Emission Control Costs for Acceptability Reductions

Emissions from the main stack did not trigger unacceptable risk levels however; emission 

reductions were required from the furnace area (baghouse #7), refining kettles (baghouse #8), 

refinery building (baghouse #9) and fugitive dust to meet acceptability requirements. Although 

costs are not considered under section 112(f)(1) (acceptability) in order to meet acceptable risk, 

EPA has estimated the cost impacts for these emission controls for the furnace area and refining 

operation stacks, and has also estimated the costs for the proposed ambient lead monitoring. 

EPA estimates that replacing existing cloth bags in all baghouses will provide an approximately 

95 percent reduction in emissions from the emission points controlled by baghouses. 

Table 3.1 summarizes the costs and cost-effectiveness upgrading existing baghouses from cloth 

bags to membrane bags. Table 3.2 summarizes the costs and cost-effectiveness of adding inseries baghouses. The calculations supporting the costs reflected in the summary are included in 

EXCEL spreadsheet DRAFT ImpactsEst_PrimLeadRTR_122210.xls found in the docket. 
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3.2 Emission Control Costs for Ample Margin of Safety Reductions

Once we ensure that the risk is acceptable, we then determine whether further reductions are 

appropriate to ensure an ample margin of safety. We investigated available and feasible control 

options that could be implemented by the facility to attain the additional emissions reductions to 

provide an ample margin of safety. 

Because all feasible controls will need to be adopted in order to meet the risk acceptability 

reductions, there are no additional controls to consider for fugitive dust emissions, the furnace 

area stack, and the refinery stacks. For the main stack, additional controls were evaluated and 

considered with regard to risk reduction and cost under the ample margin of safety analysis. 

For the main stack, our risk analysis indicates that the main stack emissions do not result in 

ambient lead levels exceeding the NAAQS based on either actual or allowable emission levels. 

However, we determined that it is technologically feasible to reduce emissions from the main 

stack to a level well below the allowable level of the MACT, since those levels are currently 

being achieved. We evaluated additional controls such as membrane bags or add-on baghouses 

as a means for achieving those reductions and reducing associated risk. We determined that the 

additional controls would not provide an appreciable risk reduction (emission reduction) for the 

associated cost. However, we have determined that emissions allowable under MACT should be 

reduced under the section 112(d)(6) technology review as described in the technology review 

memorandum found in this docket. 

Table 3.3 summarizes the costs and cost-effectiveness of upgrading existing baghouses from 

cloth bags to membrane bags. Table 3.4 summarizes the costs and cost-effectiveness of adding 

an in-series baghouse. The calculations supporting the costs reflected in the summary are 

included in EXCEL spreadsheet DRAFT ImpactsEst_PrimLeadRTR_122210.xls found in the 

docket. 
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Total Cost 

Investment

Total 

Annualized 

Cost

2008 Baseline 

Pb Emissions 

(tpy)

Emission Reduction 

from upgrade* 

(tpy)

CE 

($/ton)

Furnace area, BH 7 81,548 27,591 1.81 0.95 29,043Refining, BH 8 102,032 17,048 0.45 0.21 81,179Refining BH 9 366,932 60,471 2.03 1.3 45,467

*We estimate removal efficiency for membrane bag update to be between 50 and 70 percent.

Cost of Upgrade to

Membrane Bags

Table 3.1 - Cost Effectiveness of Upgrading Baghouses to Membrane Bags for Baghouses 7, 8 and 9

Impacts

Source

Pb emissions (tpy) 

reported in 2008 

EI

Pb emission reduction 

with additional BH 

assuming 50% RE (tpy)

Pb emission reduction 

with additional BH 

assuming 97% RE (tpy)

Annualized cost of 

adding extra BH's 

($/yr)

Cost effectiveness 

assuming 50% RE 

($/ton)

Cost effectiveness 

assuming 97% RE 

($/ton)

BH 7 1.81 0.9 1.8BH8 0.45 0.2 0.4BH 9 2.03 1.0 2.0Total 4.29 2.1 4.2 $849,750 $396,154 $204,203

1 Reflects costs for pulsejet baghouses2 See DRAFT ImpactsEst_PrimLeadRTR_122210.xls for detail on cost analysis.

RE = Removal efficiency

Table 3.2 - Cost Effectiveness of Adding Additional Baghouses to Control Emissions for Baghouses 7, 8 and 9 1,2

Total Cost 

Investment

Total 

Annualized 

Cost

2008 Baseline 

Pb Emissions 

(tpy)

Emission Reduction 

from upgrade* 

(tpy)

CE 

($/ton)

Main Stack 1,958,851 322,823 13.31 8.0 40,424

*We estimate removal efficiency for membrane bag update to be between 50 and 70 percent.

Cost of Upgrade to

Membrane Bags

Table 3.3 - Cost Effectiveness of Upgrading Baghouses to Membrane Bags for Main Stack

Impacts

Source

Pb emissions (tpy) 

reported in 2008 

EI

Pb emission reduction 

with additional BH 

assuming 50% RE (tpy)

Pb emission reduction 

with additional BH 

assuming 97% RE (tpy)

Annualized cost of 

adding extra BH's 

($/yr)

Cost effectiveness 

assuming 50% RE 

($/ton)

Cost effectivenes

assuming 97% R

($/ton)

Main Stack 13.31 6.7 12.9 $1,529,730 $229,862 $118,485

1 Reflects costs for pulsejet baghouses2 See DRAFT ImpactsEst_PrimLeadRTR_122210.xls for detail on cost analysis.

RE = Removal efficiency

Table 3.4 - Cost Effectiveness of Adding Additional Baghouses to Control Emissions for the Main Stack 1,2
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3.3 Additional Testing and Monitoring Costs

Based on the elevated risk levels found for the furnace area stack and the refining operation 

stacks, EPA is proposing emission caps for those emission points. To demonstrate compliance 

with the new emission caps and the plant—wide emission limit, EPA is proposing to require 

quarterly stack testing. Although the method for testing is the same as it was under the current 

MACT, the quarterly frequency requirement imposes additional impact with regard to the cost of 

additional testing. 

In addition, the risk analysis results indicate that modeled lead concentrations exceed the 

NAAQS at several of the property boundary receptor locations. Since the impact at these 

locations is driven by fugitive dust emissions, EPA is proposing an ambient lead concentration 

limit at the property boundary. To demonstrate compliance with this limit, EPA is proposing to 

require ambient lead monitoring at four locations that would be most representative of the 

highest modeled emissions of lead. 

The additional monitoring requirements will cause annual costs for the performance of additional 

testing and monitoring. Since EPA assumes that monitoring equipment will be leased and not 

purchased, there are no anticipated capital costs associated with the new requirements. We have 

determined the cost for the additional testing and monitoring to meet these requirements as 

summarized in Table 3.5 below. 

Table 3.5 - Additional Testing and Monitoring Costs 

Type of Testing/Monitoring Notes Cost Annual Cost1

Stack Testing Method 12 $13,000 per test $156,000 

Ambient Lead Monitoring (lab 

analysis) 

Per required monitoring plan $127 per test $185,420 

Ambient Monitoring Equipment Annual Lease $2,500 per unit $10,000 1

 Includes 12 additional stack tests (4 stacks x 3 more tests) and 4 ambient monitors, each tested 365 days per year.